EXHIBIT 5.1


              [EVERS & HENDRICKSON LLP LETTERHEAD GRAPHIC OMITTED]

155 MONTGOMERY STREET, 12TH FLOOR, SAN FRANCISCO, CA 94104     ANTOINE M. DEVINE
                                                                         PARTNER

                                                           DIRECT (415) 772-8109
                                                             MAIN (415) 772-8100
                  May 31, 2000                                FAX (415) 772-8101
                                                             DEVINE@EVERSLAW.COM

Securities and Exchange Commission
Division of Corporate Finance
450 Fifth Street, N.W.
Washington, D.C. 20549

         RE:      EASTERN MANAGEMENT CORPORATION, LEGALITY OF SHARES

Dear Madam/Sirs:

         We have  made  reasonable  inquiry  and  are of the  opinion  that  the
securities  being offered,  will, when sold, be legally  issued,  fully paid and
non-assessable.

         We are not  opining as to any other  statements  contained  in the Form
SB-2  registration  statement,  nor as to  matters  that  occur  after  the date
thereof.

                                                 Very truly yours,

                                                 EVERS & HENDRICKSON, LLP

                                                     /s/ Antoine M. Devine
                                                     --------------------------
                                                 By: Antoine M. Devine, Partner

cc:      Devinder Randhawa